The Exposure Control Plan | Bloodborne Pathogens

A written exposure control plan is necessary for the safety and health of workers. Covered employers must develop a plan that identifies and documents the tasks, procedures, and job classifications covering instances where there is exposure to blood or other potentially infectious materials.

The written exposure control plan must document the following key elements:

• Job classifications: Identify job classifications and, in some cases, the tasks where there is exposure to blood and other potentially infectious materials.

• Schedule: Outline how and when the provisions of the standard will be implemented, including schedules and methods for communication of hazards to employees, hepatitis B vaccination and post-exposure evaluation and follow-up, recordkeeping and implementation of the methods of compliance, such as:

  • Engineering and work practice controls,

  • Personal protective equipment, and

  • Housekeeping.

• Evaluation: Procedures for evaluating the circumstances of an exposure incident.

The schedule of how and when the provisions of the standard will be implemented may be a calendar with brief notes describing the methods, an annotated copy of the standard, or part of another document, such as the infection control plan.

The written exposure control plan must be accessible to employees and must be reviewed and updated at least annually and whenever necessary to reflect new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure. The review and update must also:

• Reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens; and

• Document annually consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure.

The employer must also request input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps in the identification, evaluation, and selection of effective engineering and work practice controls. This process must be documented in the exposure control plan. Planning begins with identifying employees who have occupational exposure.